1. Privacy notice. Every app should have an accessible and understandable privacy notice and terms of use agreement. At minimum, this should include how personal information is collected, used, and disclosed, for what purposes, how it is protected, and how the user can make a complaint. App developers need to be creative when presenting a lot of information in a very small display space.
  2. Identified purposes. App developers must identify the exact purposes for which information is collected, used, and disclosed, and they must be open and transparent with users about these purposes. They must ensure that the information is not collected, used, or disclosed for any other purpose.
  3. Meaningful consent. Every app must have a way of capturing meaningful consent (i.e. not a long, multi page, legal speak form with an “I agree” button at the end). The consent should be written in plain language and the consent process should be completed before any personal information is collected.
  4. Data minimization. The app should only collect, use, and disclose the minimum amount of data needed for the identified purposes. Features, such as cameras, voice recorders, and location trackers, should be disabled unless they are required for the identified purpose of the app.
  5. Data encryption. All personal information associated with the should be encrypted at all times using a strong encryption algorithm. This includes data at rest in the device, data in transit, and any backend system and database.
  6. Access control. Rigorous access control processes must be in place to manage access to the app and its associated data. This includes end-user roles (i.e. customer/patients) and admin roles (i.e. app developers and support personnel).
  7. Identification and authentication. Robust identification and authentication methods must be applied. This includes strong passwords and multi-factor authentication where appropriate.
  8. Monitoring and audit. Audit-logging capability must be built into the app to track access to personal information and to enable detection, investigation, and response to private and security breaches.